NCH Canada - Accessibility Policy and Plan - DEC-2014

NCH CANADA INC.
Integrated Accessibility Policy and Plan
Integrated Accessibility Policy and Plan

Table of Contents
I.
Statement of Commitment
II.
Objective and Scope
III.
Definitions
IV.
Responsibilities
A.
Management
B.
Supervisors
C.
Employees
V.
Procedure
A.
General Requirements
B.
Information and Communication
C.
Emergency Response
D.
Employment
E.
Accommodation Plans
F.
Performance Management, career development and job changes accessible to
employees
G.
Return to Work
H.
Websites
I.
Feedback
J.
Confidentiality
K.
Exceptions
VI.
Training
A.
Employee Training
B.
Training Records
VII.
References
VIII.
Appendices
A.
NCH Canadas Multi-Year Accessibility Plan for IASR
B.
Accessible Document Tips
IX.
Document Control
Integrated Accessibility Policy and Plan for NCH Canada Inc.
I.
Statement of Commitment
NCH Canada Inc. believes in integration and equal opportunity. We are committed to treating all
people in a way that allows them to maintain their dignity and independence by meeting the needs of
individuals with disabilities in a timely and effective manner, and will do so by preventing and
removing barriers to accessibility and meeting accessibility requirements. NCH Canada is committed
to improving accessibility and providing a barrier-free environment for all stakeholders including our
clients/customers, employees, job applicants, suppliers, and any visitors who may enter our premises,
access our information, or use our services. Our company respects and will uphold the requirements
set forth under the Accessibility for Ontarians with Disabilities Act (2005), and its associated standards
and regulations. We are committed to ensuring our organizations compliance by incorporating
accessibility legislation into our policies, procedures, equipment requirements, training, and best
practices. We will review these policies and practices annually, as organizational changes occur, or in
anticipation of compliance deadlines.
II.
Objective and Scope

The Accessibility for Ontarians with Disabilities Act, 2005 (AODA) is a law in Ontario with the purpose
of developing, implementing and mandating accessibility standards in order to achieve accessibility for
persons with disabilities, with respect to goods, services, facilities, accommodation, employment,
buildings, structures and premises by removing barriers for Ontarians with disabilities so they can fully
participate in society and the workplace. The end goal of the act and regulations is to transform
Ontario into a fully accessible province by 2025. NCH Canadas Accessibility Plan outlines the policies
and actions that will be put in place to improve on opportunities for people with disabilities. NCH
Canada will continuously improve on existing policies and develop new policies in order to provide
individuals of all abilities opportunities to participate fully in everyday life. As such NCH Canada also
recognizes that specific accommodations may be required to assist an employee or individual in an
identified disability.
NCH Canada will establish, implement, maintain, and document a multi-year accessibility plan
outlining its strategy to prevent and remove barriers and meet its requirements under the IASR.
Accessibility plans will be made available in an accessible format, upon request, and will be posted on
our website.
III.
Definitions
Whenever used in this Policy, the following words and terms have the meanings set out below:
Accessible Formats - can include but are not limited to large print, recorded audio and electronic
formats, braille and other formats usable by persons with disabilities.
Accommodation Plan - formal way to record and review things you need to do to accommodate an
employee with a disability.
Alternate Duty - duties assigned to an injured or ill employee which require the employee to transfer
to another job position or department on a temporary basis.
Implementation Date: DEC-2014

Revision Date: Authorized by: Anne Ignasz
Reviewed by: Sylvia Senoran
Version: Final 1
Distribution list: All Ontario Associates
File Location: Y:\AODA\Integrated Accessibility Standards\NCH Canada_Accessibility Policy and Plan_DEC-2014.doc
Next Review: DEC-2016

Prepared by: Sylvia Senoran
AODA - Accessibility for Ontarians with Disabilities Act

Communication Supports - include but are not limited to captioning, alternative, and augmentative
communication supports, plain language, sign language and other supports that facilitate effective
communications.
Conversion Ready - an electronic or digital format that facilitates conversion into an acceptable
format.
Disability - means:
a) any degree of physical disability, infirmity, malformation or disfigurement that is caused by
bodily injury, birth defect or illness and, without limiting the generality of the foregoing,
includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of
physical co-ordination, blindness or visual impediment, deafness or hearing impediment,
muteness or speech impediment, or physical reliance on a guide dog or other animal or on a
wheelchair or other remedial appliance or device,
b) a condition of mental impairment or a developmental disability,
c) a learning disability, or a dysfunction in one or more of the processes involved in
understanding or using symbols or spoken language,
d) a mental disorder, or
e) an injury or disability for which benefits were claimed or received under the insurance plan
established under the Workplace Safety and Insurance Act, 1997.
f) Barrier - Anything that prevents a person with a disability from fully participating in all aspects
of society because of his or her disability, including a physical barrier, an architectural barrier,
an information or communications barrier, an attitudinal barrier, a technological barrier, a
policy or a practice.
g) Individualized Emergency Response Information A plan to help an employee with a disability
during an emergency, or emergency information that is formatted so an employee with a
disability can understand it.
IASR - Integrated Accessibility Standards Regulation
Modified Work Duty/Accommodation - change, adaptation or adjustment of an employees work
and/or workplace environment to enable that employee to perform the regular duties of a job in a
healthy and safe manner.
Performance Management - activities related to assessing and improving employee performance,
productivity, and effectiveness with the goal of facilitating employee success.
Redeployment - the reassignment of employees to other departments or jobs within the organization
as an alternative to layoff, when a particular job or department has been eliminated by the
organization.
Restrictions - anything related to an illness, injury or disease that prevents an employee from
completing a particular job task/duty as outlined and supported through medical evidence.
WCAG 2.0 - is an internationally accepted standard for web accessibility developed by the World Wide
Web Consortium (W3C), an international team of experts. WCAG 2.0 sets out guidelines for
organizations to follow to make their websites more accessible for people with disabilities. The
guidelines cover things like writing web content in clear language, providing alternate text for images
and making sure someone can navigate your website with just a keyboard. Each guideline has three
levels of accessibility: A, AA and AAA. Level AAA is the highest level of accessibility.
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IV.
Responsibilities
A. Management
NCH Canada management will establish policies, practices, and procedures governing the provision of
individuals with disabilities. Any policy that does not respect and promote the dignity and
independence of people with disabilities will be modified or removed. NCH Canada management will
also receive feedback regarding NCH Canadas Policy, Plan, practices and procedures and to respond
to this feedback, when requested within the timelines identified in this policy.
B. Supervisors
Supervisors will ensure all current and future employees are trained according to this standard.
C. Employees
Employees will comply with the NCH Canadas Accessibility policies, practices, and procedures and will
comply with AODA regulations.
V.
Procedure
A. General Requirements
NCH Canada will develop, implement, and maintain policies governing how it will achieve accessibility.
NCH Canada will include a statement of its commitment to meeting the accessibility needs of persons
with disabilities. These documents will be made publicly available in an accessible format, upon
request. NCH Canada will establish, implement, maintain, and document a multi-year accessibility
plan outlining its strategy to prevent and remove barriers and meet its requirements under the IASR.
Accessibility plans will be made available in an accessible format, upon request, and will be posted on
our website. When reviewing NCH Canadas EHS Programs and Policies, Management will make every
effort to ensure that Accessibility is addressed in these programs and that additional provisions are
made. Any of our policies that do not respect and promote the dignity and independence of people
with disabilities will be modified or removed.
B. Information and Communication
NCH Canada is committed to meeting the communication needs of people with disabilities. All
information and communications materials and services provided by NCH Canada shall follow the
principles of dignity, independence, integration, and equal opportunity. Unless deemed
unconvertible, NCH Canada will provide or arrange for the provision of accessible formats and
communication supports for persons with disabilities, upon request. This includes publicly available
information about our goods, services, and facilities, as well as publicly available emergency
information. NCH Canada employees must advise the Operations Manager when an individual with a
disability requests information in an accessible way. Employees will consult with the individual with
the disability to determine their information and communication needs when customizing individual
requests. NCH Canada will work with the individual, as soon as practicable, to identify solutions and
options that take into consideration their needs and shall consult with the individual making the
request to ensure suitability. Consider how we interact with our customers or other employees.
Consider: Brochures or Catalogues, Reports and Memos, Signs, Surveys or Comment Cards, Websites,
Email, Telephone, Meetings, Presentations, and Announcements. Look for potential barriers
anything that would make it difficult for someone with a disability to read, see, hear, or understand.
Alternative options include, but are not limited to: Enlarged text; Communication support either in
person or over the phone; reading documents aloud providing/using visual aids such as videos or

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presentation, use of transcripts, documents provided via email, etc. Accessible formats and
communication supports will be provided in a timely manner and at no additional cost to the
individual. Refer to Appendix B for Accessible Document Tips. Also refer to NCH Canada Customer
Service Standard.
If an employee with a disability requests it, NCH Canada will provide or arrange for the provision of
accessible formats and communication supports for the following: Information needed in order to
perform his/her job; and Information that is generally available to all employees in the workplace.
NCH Canada will consult with the employee making the request to determine the best way to provide
the accessible format or communication support.
Unconvertible Information or Communications
If it is determined, in consultation with the requesting party, that information or communications are
unconvertible, NCH Canada will ensure that the individual who made the request is provided with an
explanation and a summary of the information. NCH Canada will classify information or
communications as unconvertible where:
1. It is not technically practicable to convert; or
2. The technology required to make the conversion is not readily available
C. Emergency Response
NCH Canada is committed to protecting the health and safety of its employees, customers, visitors,
and any other individual on, in, or around the premises. The purpose of NCH Canadas Emergency
Response Plan is to ensure human safety, minimize damage to property, and assure rapid and
responsive communication to all parties involved. As such, NCH Canada will ensure that all publicly
available safety and emergency information (e.g. evacuation procedures, floor plans etc.) is provided
in an accessible format or with appropriate communication supports, upon request. We will provide
this information in a format that takes into consideration individual needs. It is critical that all of our
employees, visitors, customers, and guests know and understand our Emergency Response Plan
Procedures. If it becomes known to an employee that the information provided is unclear or is in a
format that prevents an individual from fully knowing and understanding our process, we ask that
employees contact the Operations Manager so that alternative measures that provide our Emergency
Response Plan in a format that takes into consideration individual needs can be discussed. NCH
Canada will work with the individual requesting the information in order to identify the how we can
meet their needs as soon as possible. Also refer to NCH Canadas Emergency Action Plan.
When necessary or requested by an employee, NCH Canada will provide employees with disabilities
with individualized emergency response information and/or plans. NCH Canada will develop and
document individual accommodation plans for employees with identified disabilities. This information
will take into account the unique challenges created by the individuals disability and the physical
nature of the workplace, and will be created in consultation with the employee. If requested, and
upon approval by the individual, individual Emergency Response and Fire Evacuation Plans shall be
shared with the person designated to provide assistance to the individual with the disability. NCH
Canada Management will revisit individualized emergency response information and/or plans if the
employee moves, if there is a review of their accommodation needs, or during regularly scheduled
emergency procedure training.

Version: Final 1

D. Employment
NCH Canada is committed to fair and accessible employment practices. When requested, NCH Canada
will accommodate disabilities during recruitment and assessment processes and when individuals are
hired. NCH Canada will notify employees and the public about the availability of accommodation for
job applicants who have disabilities. Applicants will be informed that these accommodations are
available, upon request, for the interview process and for other candidate selection methods. Where
an accommodation is requested, NCH Canada will consult with the applicant and provide or arrange
for suitable accommodation. Successful applicants will be made aware of NCH Canadas policies and
supports for accommodating people with disabilities. Refer to NCH Canadas Equal Opportunity and
Non-Harassment Policy.
Redeployment
The accessibility needs of employees with disabilities will be taken into account in the event of
redeployment.
E. Accommodation Plans
Accommodation plans are a formal way of recording and reviewing things required to accommodate
an employee with a disability. When necessary or when requested, NCH Canada Management will
develop accommodation plans in a clear and consistent way by involving employees in the
development of their plans, assessing the accommodation needs of the employee, protecting the
privacy of the employees personal information, provide plans in accessible formats, and review and
update the plans with employees when required.
Plans should include: the accommodations being provided; the ways in which the employee can
participate in the development of the plan; the means by which the employee is assessed on an
individual basis; the steps taken to protect the privacy of the employees personal information; and
how it should be done; the means of providing the accommodation plan in an accessible format, based
on the employees accessibility needs; how emergency information is provided; the frequency with
which the individual accommodation plan should be reviewed or updated.
F. Performance Management, career development and job changes accessible to employees
Performance management is what is done to assess and improve an employees performance,
productivity, effectiveness, and overall success. It may be informal or formal, and can vary.
Career development can include: providing employees with learning and development opportunities,
and giving employees more responsibilities within their current positions. Job changes are when an
employee is moved to another position within the organization. NCH Canada will consider the
accessibility needs of employees with disabilities when implementing performance management
processes, or when offering career development or advancement opportunities. This can include:
Reviewing an employees accommodation plans to understand their needs and see whether you
need to make adjustments to help them succeed
Making performance management documents, such as performance plans, available in accessible
formats, such as large print, when asked, and
Providing feedback and coaching employees in a way that is accessible to them, such as using
plain language for an employee who has a learning disability.
When providing career development opportunities, consider what accommodations employees
with disabilities may need to learn new skills, or take on more responsibilities in their current
position.
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G. Return to Work
Most individuals who have sustained an injury or illness are able to return to part-time,
accommodated, or alternate work even while they are still recovering, provided that the work is
physically and cognitively suited to the injury or illness and respects the employees dignity. As per
NCH Canadas Return to Work Program, we are committed to supporting activities that lead to safe
and successful return to work outcomes and to reducing the overall number of lost workdays due to
injury or illness by returning the employee back to safe and meaningful work as soon as the employee
is medically fit. As such, NCH Canada will extend its Return to work program to include the
management of non-work related injuries and illnesses as to accommodate employees who are
absent from work due to a disability and require disability-related accommodation(s) in order to
return to work. The objectives of NCH Canadas Return to Work program are to allow the employee to
remain in the work force and resume productive employment and to enable the employee to
gradually overcome their limitations through modified-duty, or alternate work assignment.
Employees are referred to the RTW program when they are unable to perform their regular job duties
due to a medically determined physical or mental impairment caused by illness or injury for which is
substantiated with medical evidence.
H. Websites
NCH Canada will ensure that our website and all web content published after January 1, 2012,
conform to the Web Content Accessibility Guidelines (WCAG) 2.0 in accordance with the schedule set
out in the IASR. NCH Canada management will ensure that NCH Canadas Corporate Website
development team is aware of the standards and ensure that new websites meets the WCAG 2.0,
Level A standard.
Beginning January 1, 2021, all public websites and all web content on those sites published after
January 1, 2012, will conform to WCAG 2.0 Level AA, other than providing captions on live videos or
audio descriptions for pre-recorded videos. This does not include internal websites.
If it is not possible to meet the WCAG 2.0 requirements, for example, software and other tools that
predate WCAG 2.0 were used to develop website. NCH Canada will attempt to update or repair the
products used to support accessibility. If this is not possible, NCH Canada will ensure use of software
that supports accessibility next time websites are revamped.
I. Feedback
NCH Canada appreciates any feedback regarding out accessibility policies and practices as it may
identify areas requiring adjustment and will assist us in continuous improvement. NCH Canada will
ensure that all feedback processes (both internal and external) are made accessible to customers or
employees, upon request. When asked, NCH Canada will receive and respond to feedback from our
customers, employees, and members of the public who have a disability . Making feedback accessible
may mean that instead of providing only one method for feedback, such as hand-written letters, we
may accept feedback in other ways, such as over the telephone or by email, giving an individual with
low vision information in large print, and exchanging hand-written notes to communicate with a
customer who is Deaf, emailing or phoning individuals in order to deliver content. NCH Canada will
respond within 21 working days.

Version: Final 1

Feedback may be provided directly to:

Anne Ignasz, NCH Canada Facility Manager
Mail: 247 Orenda Road Brampton, ON L6T 1E6
Telephone: (905) 457-5220 Ext#212
Email: anne.ignasz@nch.com
J. Confidentiality
Supervisors and those involved will maintain confidentiality of any individualized accommodation
plans. Parties involved in an accommodation process will not disclose information to other parties
without consent from the accommodated employee.
K. Exceptions
The Information and Communications Standard does not apply to:
a. Products and product labels;
b. Unconvertible information or communications; or
c. Information that the organization does not control either directly or indirectly through a
contractual relationship
VI.
Training
A. Employee Training
NCH Canada will train employees on the existence and content of this Policy, Ontarios accessibility
laws, and accessibility aspects of the IASR and Human Rights Code as it relates to people with
disabilities. Training will be provided in a way that best suits the duties of employees. Training will be
part of NCH Canadas New Hire Orientation Training. Training will also be provided to individuals who
are responsible for developing NCH Canadas policies. Training will be provided as soon as is
reasonably practicable and on an ongoing basis as changes to NCH Canadas accessibility policies
occur.
B. Training Records
The EHS Coordinator will maintain records on the training provided, when it was provided and the
number of employees that were trained. Documentation of employee training must include names of
participants and dates of training.
VII.
References
1.
2.
3.
VIII.
Accessibility for Ontarians with Disabilities Act, S.O. 2005

Ontario Regulation 429/07 - Accessibility Standards for Customer Service
Ministry of Community and Social Serviceswww.mcss.gov.on.ca/en/mcss/programs/accessibility
Appendices
A.
B.


Version: Final 1

IX.
Document Control
NCH Canada will review Accessibility policies and plan regularly to ensure that it is reflective of NCH
Canadas current practices and legislative requirements by the Facility EHS Coordinator, reviewed by
the Facility Manager and final approval will be given by NCH Canada Management. Annual status
reports will be prepared that will report on the progress of the steps taken to implement NCH
Canadas accessibility plan. This status report will be posted on our website. If requested, the report
shall be created in an accessible format.
Document History
Procedure version Date Approved
Approved by
Reason for Change
Accessible formats of this document are available free upon request from: Anne Ignasz

Version: Final 1

Appendix A

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10

Appendix A

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11

Appendix B

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12

Appendix B

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NCH CANADA INC.

Integrated Accessibility Policy and Plan

Integrated Accessibility Policy and Plan

Objective and Scope

Integrated Accessibility Policy and Plan for NCH Canada Inc.

Objective and Scope

Implementation Date: DEC-2014

Next Review: DEC-2016

AODA - Accessibility for Ontarians with Disabilities Act

Next Review: DEC-2016

Implementation Date: DEC-2014

Next Review: DEC-2016

Implementation Date: DEC-2014

Next Review: DEC-2016

Next Review: DEC-2016

Implementation Date: DEC-2014

Next Review: DEC-2016

Feedback may be provided directly to:

Accessibility for Ontarians with Disabilities Act, S.O. 2005

NCH Canadas Multi-Year Accessibility Plan for IASR

Implementation Date: DEC-2014

Next Review: DEC-2016

Reason for Change

Implementation Date: DEC-2014

Next Review: DEC-2016

Implementation Date: DEC-2014

Next Review: DEC-2016

Implementation Date: DEC-2014

Next Review: DEC-2016

Implementation Date: DEC-2014

Next Review: DEC-2016

Implementation Date: DEC-2014

Next Review: DEC-2016

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